Data Protection and Confidentiality

Protection and Privacy

Polleo Sport respects visitors' privacy and will collect visitors' personal data such as name, address, phone number or email address only if it is voluntary. We will use such data only in order to satisfy your needs. We expressly state that Polleo Sport will not sell or otherwise use your personal data and will not transfer it to any third party without your consent. Any changes to the Internet Privacy Policy will be announced by Polleo Sport on this website or made available to you in another convenient way.

Company rights of personal data

Identity and contact details of the Controller:

Name: Ahema DOO Skopje

Headquarters: Zagrebska 28b

e-mail: info@ahema.com.mk

Contact details of the Personal Data Protection Officer:

Name and Surname: Emilija Angjelkoska

Phone number: 02/3110-106

e-mail: info@ahema.com.mk

Our vision for personal data protection

AHEMA DOO Skopje pays great attention to the protection of personal data in all business operations, implementing the standards set out by the regulations for privacy and protection of personal data in the Republic of North Macedonia, which are elaborated in more detail in the internal Policies and Procedures that make up the personal data protection system of AHEMA DOO Skopje

The privacy policy is published on our website: www.polleosport.mk

Introduction

This Policy can be altered at any time. All changes will be visible to you as our users. You will be notified about all changes, alterations and amendments done to this Policy via e-mail (if possible) or via any other suitable way.
The purpose of this document is to explain to you what exactly we do with your personal information. This document describes the way in which we collect, use and handle your personal information and how we fulfill our legal duties.
Your privacy is important to us and we care about the safety and protection of your rights.

Information we collect from you

We collect only information which ensures that we provide good user experience on our website.

Generally, we separate the information into:

(a) personal data that you provide and

(b) personal data collected automatically

(c) personal data collected from a third-party source

Personal data that you provide

We collect data that you provide when you register on our website, when you sign up for our newsletter or when you order from our Web shop – in all these instances, you fill out certain fields and click on a certain button which potentially provides us with your personal information. We also collect information via questionnaires, when you contact our customer support center, when you participate in a game or competition that we organize. When you provide feedback for one of our products, or file a complaint about a certain product, it is also likely that we will collect some personal data. All this information is collected with your consent, for instance, when we need to respond to a complaint about a product.

Personal data collected automatically

There is also personal information collected automatically, i.e. information saved when you use our web pages or use our services. Whenever you use our web page or read our email, certain information (not necessarily your personal information) is created and automatically collected. For example:

•               A cookie is a small piece of data sent from a website and stored on your computer by your web browser while you are browsing. Cookies usually save your settings, web page settings such as preferred language or internet address. Later, when you open the same web page again, the web browser sends back cookies which are tied to that page. This makes it possible for the page to display information tailored to your needs. Cookies can collect a wide range of data, sometimes including personal information (such as your name or email address). However, this data can only be saved with your consent – web pages cannot gain access to information you did not give access to. The process of saving and sending cookies is not visible to you. You can find out more about cookies further in this Policy.

Besides cookies, the information about the type of device which you use can be visible to us, along with the specific make and model of the device, which OS you use, its settings and for example, the reason why a web page „crashed“. For example, various information can be displayed depending on whether you use a PC or Mac, and iOS device or an Android device.

When you visit our stores, you should be aware that, for security reasons, some of them might be under video surveillance. This kind of surveillance can record you during your visit to our branch. We collect this data for our legal interests, and for the purpose of this Policy we consider them as Personal information collected automatically.

Personal information collected from a third-party source

Lastly, it is possible that we collect your personal information from a third-party source. For example, it is possible that we collect your personal information via social networks, in case you „like“ our page on Facebook or start following us on another „social networking site“. In that case, it is possible that we will collect your personal

information from those pages, and we will use them exclusively for our legal interests, and for the purpose of this Policy we consider them as Personal information collected from a third-party source.

Safety of personal information

Personal information that is exchanged between you and us and via our web site is transferred via modern networks. All IT systems that are used are protected from unauthorized access, and employees are required to keep all data secretive. However, Polleo Adria Ltd. does not have effect on data transfer via internet and therefore cannot protect from misuse by a third-party. The data is stored for further processing

How we use your personal information

We use your personal information appropriately in situations where the processing of your personal information is required, such as:

· to ensure a fast and precise delivery of your order;

· to track your order placement and remove any inconvenience during delivery;

· to be able to replace a faulty product, or compensate in another way;

· to offer you products and services at discount prices, or tailored to you;

· to inform you of our marketing activities and/or market research.

With whom do we share your information?

When it is necessary, we will share your personal information with the following groups of recipients:

· Polleo Sport associates an its branches, including Polleo Sport associates in other countries;

· Third-parties that have information on your finance, such as financial and credit institutions;

· Public-legal authorities, when we act in good faith, we have reason to believe that it is necessary to act in accordance with legal obligations;

· Other service providers which provide a certain service on our behalf (for example couriers) or possibly third-party IT service providers with whom we have certain agreements regarding personal information processing (or other suitable mechanisms) .

Your rights

One of the main goals of the GDPR act is to protect and define a person's rights regarding privacy protection. Even if we already process your personal information, you have certain rights.

In order to exercise these rights, please contact us. We will abide your request immediately. Please note that we will keep track of received requests, in order to solve any potential disagreements.

By the GDPR act, you have the following rights:

Right to a complaint

This right enables you to file a complaint about the processing of your personal information, in case we process your personal information on one of the following legal basis:

· because the processing of personal information is in our legal interest;

· in order to fulfill our part of the contract agreement; or

· for scientific, marketing or statistical purposes.

Under these circumstances, the most applicable case is the processing of your personal information on the basis of legal interest. If we are not able to prove that we have a believable and legitimate reason to process your personal information, we will stop processing your personal information.

Right to withdraw consent

In cases where we have your consent to process information, you have the right to withdraw the given consent at any time and we will stop using your personal information for that purpose, unless we believe that there is an alternative legal basis on which we could justify further processing of your personal information, in which case you will be notified.

Right to access

At any time, you are authorized to request a copy of the information which we have about you, or request a change, update or deletion of the information. We may ask for further information about your request. If we give you access to the information we have about you, we will do it free of charge, unless the request is “obviously unfounded or excessive”. In case you request additional copies of this information, we might charge a proportional administrative fee. Your request can be denied in cases where it's legally allowed.

Right to have the information deleted

Under certain circumstances, you are authorized to request a deletion of your personal information. For example, you have this right in the following cases:

- Your information is no longer needed for the purpose for which they were initially collected;

- You withdrew the consent for the processing of personal information that you gave us, and there is no other legal basis on which we can continue processing your personal information;

- Information is processed without a valid legal basis;

- The deletion is required in order to abide to our legal duties according to law;

You filed a complaint about the processing of personal information, and we are not able to prove the existence of a legal basis that overcomes your rights and interests on which we would be authorized to continue processing your personal information.

We are authorized to decline your request to delete your personal information in a limited amount of cases and in those cases we will explain the reasons of declining to you in detail.

Right to limit processing

Under certain circumstances, you have the right to limit the processing of your personal information, for example, in case you deny the accuracy of the personal information we have about you or if you file a complaint about the processing of your personal information on the basis of our legal interest. If we share your personal information with third parties, we will inform you about the limit of processing. Of course, we will inform you about any changes to the limitations in the processing of your personal information.

Right for correction

You have the right to request correction of any incorrect or incomplete information that we have about you. You are also authorized to request information about third parties to which we gave your personal information. In case we believe that we cannot reasonably accept your request, you will be informed and given an explanation about such decision.

Right to transfer

If you want so, you are authorized to request a transfer of your personal information to another controller. This means that it is possible for your personal information to be transferred to a third party. In order to make that possible, we will give you all of your information in a common, machine-readable form so that you can transfer your information to a third party. This right is applicable for: (i) automatically collected data (no human factor involved); (ii) data given to us by you; and (iii) data that we collect and process based on your consent or in order to fulfill our end of an agreement.

How long we keep your personal information

According to your rights, the information will be kept in accordance to relevant legal regulations, and how long we keep the information can depend on fulfilling our obligations based on a certain regulation.
In any case, when we confirm that we no longer need your information and that legal deadlines for keeping personal information are due, we will delete all personal information about you that we have.

How you can prevent the use of your personal information for direct marketing purposes

The use of Google Analytics

This website uses Google Analytics for web analysis. The supplier is Google Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA

Google Analytics uses cookies.

When you visit this website, cookies are used to generate data that Google collects and processes. You can prevent this by downloading and installing this web browser add-on: https://support.google.com/analytics/answer/6004245?hl=en_US

You can find more information about the use of user data on Google Analytics in Google's Privacy Policy: https://tools.google.com/dlpage/gaoptout?hl=en_US

Promotional offers delivered via email (Email Newsletter)

You can sign up for our newsletter via our website. For this we need your email address and your consent to receive newsletters. We process and use other information about the company, address and fields of interest to send requested information. They will not be forwarded to third parties.

You can withdraw your consent for information saving, use of your email address to deliver newsletter at any time – you can do this via links in every email newsletter or by directly contacting shop@polleosport.mk. In that case, we will immediately delete your information regarding newsletters.

To distribute newsletters, we use the system MailChimp (trademark of Rocket Science Group, LLC, 675 Ponce De Leon Ave NE 5000, Atlanta, GA 30308, USA). MailChimp complies with the “Privacy Shield” data protection agreement and must abide to privacy policies of the EU.

MailChimp's Privacy Policy: https://mailchimp.com/legal/privacy/ will use your information only to deliver newsletters, estimate deliveries and improve services. MailChimp will not contact you direclty nor use your information. They will not send your information to third parties. During that process, the information about your web browser, your IP address and your location will be sent to MailChimp.

Legal basis and purposes for your personal data processing

Users’ rights

The users (personal data subjects) have the right:

- to be informed about the processing of their personal data

- to be able to access their personal data and to supplement, modify, delete or request termination of the use of their personal data

A more detailed explanation regarding these rights follows:

- In the interest of transparency, AHEMA DOO Skopje undertakes to inform the user of the purposes and legal basis of the processing of his personal data.

- Every user has the right to access their personal data.

The request for access to the data is submitted in writing in one of the stores of AHEMA DOO Skopje or filled out on one of the digital channels of AHEMA DOO Skopje.

AHEMA DOO Skopje must respond to the user within 15 days from the day of receipt of the request, and is under no obligation to respond to the same or similar request again, if there are no changes in their personal data in the meantime, unless 6 (six) months have passed from the date of submission of the previous request to the new request.

If the user does not receive a response to the request for access to personal data, they can submit a request to determine a violation of the right to protection of personal data to the Personal Data Protection Agency.

The user has the right to request addition, modification, deletion or termination of the use of their personal data.

If requested by the user, AHEMA DOO Skopje is obliged to supplement, modify, delete or stop the use of personal data, if the data is incomplete, incorrect or not updated and if their processing is not in accordance with the law.

Regardless of whether the user has submitted a request for addition, modification or deletion of personal data, if AHEMA DOO Skopje determines that the personal data are incomplete, incorrect or not updated, it is obliged to add, modify or delete it. AHEMA DOO Skopje is obliged to notify the subject of personal data in writing about the additions, changes or deletions made, no later than 15 days from the day of receipt of the request.

How long we keep your personal data

The information processed by AHEMA DOO Skopje for the purpose of exercising your rights will be kept in accordance with legal deadlines, and the information processed in accordance with the given consent will be stored until your consent to their processing for the specified purpose is withdrawn.

What are your rights?

In order to exercise your rights arising from the Personal Data Protection Law (right to access, correction, deletion, limitation of the processing of your personal data, objection and transferability), send a request to the email address of the personal data protection officer: info@ahema.com.mk Emilija Angjelkoska

If you believe that any of your rights to the protection of personal data have been violated, you have the right to submit a request for determination of a violation of the regulations on the personal data protection to the Personal Data Protection Agency as the competent authority for supervising the legality of the activities undertaken during the processing of personal data in the territory of the Republic of North Macedonia.

Below are the requests which are submitted if you want to withdraw the consent for use of personal data or to stop the procedure for personal data processing.

Requests should be submitted electronically to: shop@polleosport.mk

1.1

Request to withdraw consent for the use of personal data

Pursuant to Article 13а of the Personal Data Protection Law, hereby I withdraw the consent for the use of my personal data given to AHEMA DOO Skopje for the purpose of notices in electronic form

Name and Surname ____________________________________________________________

Date of Birth ___________________________________________________________

Personal Number _____________________________________________________________________

Address ________________________________________________________

Date of Consent Withdrawal  ________________________________

Phone Number*__________________________________________________

Email* __________________________________________________________

AHEMA DOO Skopje will make every effort to respond to the subject's request within 15 days from the receipt of the request or from receiving the additional information if the initially submitted request is unclear or incomplete.

*Fields marked with * are optional, and have been placed in order to facilitate the communication with the applicant if there is a discrepancy in the data.

Signature

2.1

Request to stop the processing of personal data

To be filled in by the personal data subject

Name: _____________________________________________

Surname: _____________________________________________

Phone: _____________________________________________

Email address: _____________________________________________

Reply to address:                                          _____________________________________________

I request to stop the processing of my personal data by Ahema DOO Skopje.

These are the reasons for the request: ______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

Request for addition, modification or deletion of personal data processing information

To be filled in by the personal data subject

Name: _____________________________________________

Surname: _____________________________________________

Phone: _____________________________________________

Email address: _____________________________________________

Reply to address:                                          _____________________________________________

Pursuant to the provisions of the Personal Data Protection Law, I request (check one of the following)

• addition

• change

• deletion

of the following personal data:

_______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

Signature